ML19248C817
| ML19248C817 | |
| Person / Time | |
|---|---|
| Issue date: | 03/30/1979 |
| From: | Brickley R, Hale C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19248C794 | List: |
| References | |
| REF-QA-99900526 99900526-79-1, NUDOCS 7907050109 | |
| Download: ML19248C817 (6) | |
Text
U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION IV Report No.
99900526/79-01 Program No.
51200 Company:
Black and Veatch Consulting Engineers cost Office Box 8405 Kansas City, Missouri Inspection at:
Overland Park, Kansas Inspection Conducted: March 12-16, 1979 i
l Inspector: 7. /V 3 dbte 9/30!79 l
R. H. Brickley, Principal Inspector, Vendor Date Inspection Branch Approved by:
N Nd
[
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C. J. Male / Chief, Program Evaluation Section, Date i
Vendor Inspection Branch Summary Inspection conducted March 12-16,1979j99900526/79-01) l Areas Inspected:
Implementation of tne requirements of 10 CFR Part 50, Appendix B, in the areas of design inspection - containment spray system, and action on previous inspection findings.
The inspection involved thirty-two (32) inspector-hours on-site by one NRC inspector.
Results:
No unresolved items were identified in any area. The following two (2) deviations were identified.
Devi ations : Design Inspection - containment spray system - deviations from QA Program - Nuclear requirements were authorized without the approval of the QA Manager (Notice of Deviation, Enclosure, Item B) and drawings had been approved without an independent check and signoff by the checker (Notice of Deviation, Enclosure, Item A).
q907050 #
285 30%
Details A.
Persons Contacted
- R. E. Blaisdell, QA Manager L. Drbal, Group Leader, Systems Department M. A. Robinson, Mechanical Engineer M. J. Robinson, Project Manager
- C. J. Ross, Manager, Design W. J. Zidziunas, Project Design Engineer, Mechaniccl
- Denotes those present at the exit interview B.
Action on Previous Inspection Findings 1.
(0 pen) Deviation (Report No. 78-01): The Project Design Manual, the Quality Assurance Prcgram - Nuclear Manual and their revi-sions are not being maintained in the QA record system.
The inspector verified the corrective actions taken as stated in the Black Veatch (B&V) response to the inspection report dated September 7,1978, i.e., directives were issued (Scptember 8, 1978) to the Project Manager and Supervisor of the Power Divi-t l
sion Document Controi Center to provide copies of the Project s
Design Manual and Quality Assurance Program - Nuclear Manual to the Project Document Control Administrator for inclusion in the Quality Assurance Records System. The re-examination of the Quality Assurance Program that was committed in the B&V letter of September 7,1978, had been rescheduled for completion by March 30,1978, per their letter of February 2,1979 and was still in progress at the time of this inspection.
This item will be re-examined during the next inspection.
2.
(Closed) Deviation (Report No. 78-01):
Procured services (ex-ternal), document control, and QA records are not being audited at a frequency consistr.nt with ANSI N45.2.12.
The inspector verified the completion of the corrective actions and preventive measures contained in the B&V responses to the inspection report dated September 7,1978, October 4,1978, and February 2,1979 i.e., the investigation of the audit activities associated with Sharr.on and Wilson, the training that was conducted, and the audit of document control and QA record system (Audit Report 78P10).
3.
(Closed) Deviation (Report No. '/-01): Failure to comply with Section 4 of ANSI N45.2.12 in that internal audits were not being documented, reports not signed, reports not issued in 30 days and that post-audit conferences wese not conducted.
The 28
'iO9
inspector verified the completion of the corrective actions and preventive measures contained in the B&V responses to the inspec-tion report dated September 7, 1978 and Cctober 4, 1978 i.e.,
and audit checklist was added to the B&V QA Group Instructions, and the QA Manager's re-examination of the lf /7 and 1978 audit reports and correction of deficiencies.
C.
Design inspection - Containment Spray System 1.
Objectives The objectives of this area of the inspection were to verify for the contaimnent spray stem that:
a.
Design criteria, requiremants and commitments, as listed in the SAR, were utilized in design input during system and component design.
b.
Analyses of containment pump net positive suction head (NPSH) during all phases of operation follow the guidance of Regulatory Guide 1.1.
c.
Design analyses establish the capability of the system to provide flow at rates and temperature which result in heat removal rates consistent with those utilized in the LOCA and/or main steam line break.nalyses.
d.
Specifications and/or procurement documents for system com-ponents require them to be designed, faoricated, erected aad tested in accordance with applicable ASME Section III and 10 CFR 50, Appendix B, requirements.
e.
Provisions and plans have been made for pre-operational and operational testing consistent rith SAR commitments and statements.
f.
The analysis (design) of system spray coverage supports SAR commitments and statements.
g.
The system design for pH control including analyses of pH versus time after system actuation supports SAR commitments and statements.
h.
Provisions to prevent trapping of chemical additives imple-ment SAR comnitments.
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. 1.
Calculations of iodine removal constants, use parameters, and system characteristics are cons'etent with those in items a-h, above.
j.
Iodine removal constants used in the analyses of the radiological consequences of a LOCA are consistent with item i., above.
2.
Method of Accomplishment The preceding objectives were accomplished by and examination of:
a.
Sections 6.2.2 (Containment Heat Removal System), 6.2.3 (Containment Air Purification and Cleanup System), and 17.B.1.3 (Design Control) cf Project No. 621?. PSAR for the technical and progrannatic commitments.
b.
Sectic.s 1.2 (Regulatory Requirements), 2.0 (System Desig-nations), 3.2 (Classification of Systems, Structures, and Components), 3.4 (Design Input Requirements), 3.5 (Codes and Standards), 4.0 (Items Covered b.v QA Program), 5.6 (De-sign of Mechanical Systems and Components), 5.11 (Radio-j logical Dose Calculations), 6.0 (Component Design Criteria),
q and 6.2 (Mechanical Components) of the Project Design Manual; and Standard Procedures No. 3.3 (System Design Specifica-tions), 3.4 (Component Design Specificatier.s), 3.5 (Hand-written Calculations), 3.6 (Computer Calculations), 3.7 (Computer Program Verification), 3.9 (Design Verification),
5.2 (Drawings and Lists), and 6.1 (Control of QA Program Documents) of the Quality Assurance Program - Nuclear Manual to detemine that they were consistent with SAR ccamitments.
c.
System Design Specification - Residual Heat Removal System, Revision 2, dated April 2,1977 and Engineering Change No-tices No. N-I-0085, N-I-0107, and N-I-0118, to verify that it satisfied C.1.a and the requirements of the applicable documents of C.2.b above.
d.
Calculations No. 6212.215.2417.13I01 (Containment Spray System Ufect of pH on Spray Removal Coefficient) Revi-sion 0,s 2d December 22, 1976, 6212.213.3012.13I01 (Con-tainment Spray System - Iodine Removal Coefficients' Revi-sion 0, dated April 12, 1976, and their Calculatica Review checklists to verify that they sctisfy C.1.i anc the re-quiremt s of the applicable docu'nents of C.2.b above.
285 3 p
. e.
Calculations No. 6212.213.7519.13IO2 (LOCA Activity Release Analysis - Conservative) dated February 25, 1977, 6212.213.
7519.13103 (LOCA Dose Analysis - Conservative) dated February 23, 1977, and their Calculation Review Checklists to verify that they satisfy C.1.j and the requirements of the applicable documents of C.2.b above.
f.
Spacification No. 312.6110 (Fabricated Nping I) dated October 5,1978, to verify that it satisified C.1.d and the requirements of the applicable documents of 0.2.b above.
g.
The B&V Drawing List dated March 1, 1979 and drawings No.
M1305 A, B, & C (P&ID Residual Heat Removal System) all Revision B, dated April 27, 1478, M4008A and B (Detail Piping, Reactor Area, RHR System "A" - Plan) both Revision 1, dated August 30, 1978, and M4009A and B (Detali Piping, Reactor Area, RHR System "A" - Sections) both Revision 1, dated August 30, 1978, to verify that they satisfied C.I.d and the requirements of the applicable documents of C.2.b above.
3.
Findings a.
There.were no unresolved items and two (2) deviations identified (See Enclosure - Notice of Deviation).
b.
With respect to Notice of Deviation, Item A, it was first identified during the examination of drawing M4009A (para-graph C.2.b above) and confirmed throug. a random examina-tion of four (4) additional drawings from the mechanical discipline.
An examination of drawings from the electrical discipline did not reveal any similar deviatio :s.
c.
This project is a BWR, therefore objectives C.19 and C.1.h.
are not applicable.
d.
An iodine partition coefficient (H) of 339 was used to calculate the decontamination factor (DF) of 57 for elemental iodine.
Section 8.3.4 of ANSI N581(PWR and BWR Containent Spray System Design Criteria). Draft 7, June 1977, allows use of an H of 100 when no ch.acal additives are utilized as in this case.
With this restriction (H=100) the inspector calculated a DF of 17.5 for this project.
Referring to Sec-tions 6.2.3.3.1 (Iodine Removal Performance) and 6.2.3.3.2.1 235
- L
. (Iodine Retention by Spray Solution) of the PSAR, the in-spector verified that a DF of 57 based on an H of 339 was identified to NRR, therefore no further action by NRC:IV is contemplated.
e.
The examination of calculation No. 6212.213.3012.13I01 (paragraph C.2.d) revealed ar. error in the calculation of The value obtained should have been 1.90 x 10'4 and u
j y.
not 1.86 x 10-4 as indicated.
Discussions with B&V engi-neers indicated that this quantity, as used, wculd have no significant effect on the results obtained.
f.
The examination of calculation No. 6212.213.7519.13I03 (paragraph C.2.e) revealed an error of a factor of 10 in the calculation of the iodine - 132 and 135 concentrations.
They were calculated to be 1.0 x 102 when they should have 1
been 1.0 x 10. These values were then used to calculate the iodine released to the environment, dose at the worst site boundary and total dose.
In the latter case the value obtained was 1.1 x 100 when it should nave been 8.3 x 10-1 Since this error resulted in a more conserva-tive value for these items no further action by NRC:IV is contemplated.
It should be noted that in both cases (C.2.e and C.2.f) the calculations had been independently reviewed without these errors being identified.
D.
Exit Interview An exit interview was held with management representatives on March 16, 1979.
In addition to those individuals indicated by en asterisk in paragraph A, those in attendance were:
P. J. Adam, Head of Power Division R. M. Butcher, Manager of Engineering The inspector summarized the scope and findings of the inspection.
Management comments were generally for clarification only, or acknowledgement of the statements by the inspector.
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